SME Tax News

In Nicholas Millican v HMRC [2024] TC09239, the First Tier Tribunal (FTT) found that the post-July 2015 carried interest rules did not apply for Capital Gains Tax (CGT) purposes. Although the individual supplied investment management services, they were not supplied to an investment scheme.

In its latest one-to-many campaign, HMRC is writing to Persons with Significant Control (PSC) who have not filed a tax return or may not have declared all their income, according to the Institute of Chartered Accountants in England and Wales (ICAEW). We note that HMRC's letter will count as a 'prompt' if any income or gains have not been reported under Self Assessment.

In Roy Bevan v HMRC [2024] TC09225, a landlord was unsuccessful in his appeal against tax penalties assessed for his failure to declare small amounts of rental income over 15 years. The tribunal decided that "it was not objectively reasonable" for the Appellant to have failed to consider the ramifications of renting out a property.

In Centrica Overseas Holdings Limited v HMRC [2024] UKSC 25, the Supreme Court (SC) confirmed that professional fees incurred in relation to the disposal of a subsidiary were management expenses. However, the SC agreed with the Court of Appeal (CoA) that these expenses were capital in nature and should therefore be disallowed.

HMRC have issued the latest round of one-to-many letters, focusing on Construction Industry Scheme Insurance Sector Registrations. 

HMRC have published their Employer Bulletin for July 2024. We have summarised the key content for you, with links to our detailed guidance on the topics covered.

In Martin Laker v HMRC [2024] TC09224, the First Tier Tribunal (FTT) found that for pensions Fixed Protection 2012 purposes, a ‘year’ was not 12 consecutive months.

On 31 July 2024, second payments on account of 2023-24 Income Tax and Class 4 National Insurance liabilities fall due. This year, there’s potentially more to consider than usual.